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Four Strategies and Five Legal Arguments To Defend Your Company Against EPA’s Benzene Enforcement Initiative

The U.S. Environmental Protection Agency’s (EPA) latest attempt to replace rulemaking with enforcement is in full force, notwithstanding a spate of historic Supreme Court decisions reflecting keen frustration with federal...more

EPA Issues Enforcement Alert Targeting BWON and QQQ Noncompliance at Refineries and Chemical Manufacturers

The U.S. Environmental Protection Agency’s (EPA) Office of Civil Enforcement recently published an Enforcement Alert with the purported objective of “reminding” companies of their compliance obligations under the Benzene...more

D.C. Circuit Vacates Key Element in HFC Rules under AIM Act

A new D.C. Circuit opinion addressed the limits of non-delegation doctrine, upheld the U.S. Environmental Protection Agency’s (EPA) authority to regulate HFC/HFO blends, and struck down the agency’s authority to enact...more

EPA Publishes MON RTR, But Delays Responding to Comments on Its Controversial Risk Assessment for Ethylene Oxide

On August 12, the United States Environmental Protection Agency (EPA) published the final “residual risk and technology” (RTR) rule for the Miscellaneous Organic Chemical Manufacturing (MON) source category (Final Rule or MON...more

EPA Proposes New Clean Air Act Standards for Methane and VOC Emissions by the Oil and Natural Gas Sector

The U.S. Environmental Protection Agency (“EPA”) has released the text of a draft proposed rule that seeks to amend the new source performance standards (“NSPS”) addressing methane and volatile organic compounds (“VOC”) from...more

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